Representation to extend the due date of filing of Audit reports under Income Tax Act, 1961, from 30th September, 2022 to 31st October, 2022.

 ALL INDIA FEDERATION OF TAX PRACTITIONERS

Dated: September 19,2022

To,

1. Smt. Nirmala Sitharaman Ji,
The Honorable Union Finance Minister,
Ministry of Finance, Govt of India,
North Block, New Delhi – 110001.

2. Shri Tarun Bajaj Ji,
The Honorable Revenue Secretary,
Ministry of Finance, Govt. of India,
North Block, New Delhi – 110001.

3. Shri Nitin Gupta Ji,
The Honorable Chairman,
Central Board of Direct Taxes,
Ministry of Finance, Govt. of India,
North Block, New Delhi – 110001.

Subject: Representation to extend the due date of filing of Audit reports under Income Tax Act, 1961, from 30th Sept., 2022 to 31st Oct., 2022.

Honorable Ma’am and Sir’s,

Our Organization, All India Federation of Tax Practitioners (‘AIFTP’), is one of the largest professional bodies of tax practitioners comprising of Tax Professionals, Advocates & Chartered Accountants.

As your honour is aware now this is the fag end of the due date being 30th   Sept., 2022 for filing of audit reports by audit taxpayers.

Owing to various reasons, we request your honours that the due date for furnishing of the audit reports under various provisions of the Income Tax Act (‘the Act’) may kindly be extended from 3oth Sept., 2022 to 31st Oct., 2022.

Some of the reasons, owing to which, we request that the due date may kindly be extended are as under:

1. This year clause 30(c) and clause 44 of tax audit report in form 3CD has been made compulsory which is consuming lot of time in preparation of 3CD audit reports :-

Clause 44 of the 3CD audit report contains 7 columns to be filled up regarding expenditure towards goods and services from registered and unregistered entities. Column 5 of the said clause requires to furnish, “total payment to registered entities”. There is need to issue clarification by CBDT that whether “payment” under this column means to include payable also or only the actual payment during the year, further it also needs to be clarified by CBDT that the Payment under this column refers to include payment relating to purchases or expenditure incurred during the current year or any earlier year also or any advance payment for goods or services also. Further column 2 of clause 44 needs to mention total amount of expenditure incurred during the year, whether this includes Non-GST supplies also e.g. Salaries are also to be included here or not, as this needs to be clarified by CBDT. The compilation of these information’s for clause 44 may be for the purpose which shall not be served if  desired information  which is nowadays already available with the GST department on its portal  and if  it is synchronized with income tax portal by way of 26Q through 206C(1H) and 194Q etc may fulfill the purpose  But  compilation of information for clause 44 is not correctly possible whereas the tax auditor has to report correctness of data and information provided in 3CD as well as in clause 44 of 3CD, it seems that not even a single 3CD in India can provide correct data being furnished in clause 44 not because of ignorance or so but because of non-clarity of information required under these clause in absence of any proper guideline issued by CBDT.

2. Other clauses of 3CD:- information required to be furnished in clause 16(d) is also not clear in absence of proper guideline because during the AY 2021-22 many of the taxpayers had furnished information in clause 16(d) which resulted in double tax demand on them and still they are facing problems and even having to go to file appealsagainst these.

3. Clause 12 of 3CD also needs clarity :- because the said clause requires to furnish information relating to profit and gains relating to business covered U/s 44AD and 44AF and furthermore the 3CD utility provided on income tax portal also has mentioned section 44ADA which is not there in the notified 3CD tax audit format. CBDT is requested to clarify that here in clause 12 reference of Section 44AD and 44ADA and 44AF has become redundant/not required, because 44AF has become obsolete since long and 44AD as was desired has become redundant since long, because nowadays if any person is subjected to tax audit then he cannot opt for44AD or 44ADA along with tax audit therefore this will result in incorrect reporting in absence of proper guideline.

4. Clause 27a of 3CD requires information relating to CENVAT whereas utility provided by income tax portal has suo-moto asked for details of ITC (Input Tax Credit) even if not corresponding amendment in notified form 3CD, therefore taxpayers are in dilemma whether to replace CENVAT with ITC or to ignore this clause in absence of suitable modification in notified 3CD.

5. This year there are so many changes in the provisions relating to charitable and religious trusts and institutions etc. which also requires a lot of man hours to compile and present the information in audited financial statements of such entities and their audit reports.

6. Further the audit needs attest function by Chartered Accountants and much time has elapsed in waiting for clarity from CBDT in various such clauses of 3CD etc. now very less time has left only 10 days are left so this will be very less and so it is requested that the due date for audit reports may kindly be extended by one month.

Thus, in the said circumstances, it is most humbly Prayed, that the due date of furnishing audit reports may kindly be extended from 30th Sept., 2022 to 31st Oct., 2022 to avoid any genuine hardship to the taxpayers.

Furthermore, we as tax professionals, ensure that taxpayers and their auditors correctly file their income tax returns and duly discharge their liability.

Thus, in view of the above, we request your honor to kindly extend the due date of filing of audit reports from 30th Sept., 2022 to 31st Oct., 2022.

We trust your honors will accede to our above request.

Thanking you,

Yours faithfully,

For ALL INDIA FEDERATION OF TAX PRACTITIONERS

Adv. D.K. Gandhi Adv. Arvind Shukla CA. Jamuna Shukla
National President

A.I.F.T.P.

Chairman

Direct Tax Committee, A.I.F.T.P.

Secretary General

A.I.F.T.P.

Delhi

Mob: 9810216801

Varanasi

Mob: 9415201059

Varanasi

Mob: 9450361366

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95 Comments

  1. Chandrashekhar Trivedi says:

    Respected Madam
    Please extend due date for filing Tax Audit Report for FY 2021-22 for at least one month. It is my humble request.

  2. Y S Phani Kumar says:

    Why all these Cock and Bull Stories. We are missing to celebrate Vinayaka Chathurthi, Dussera, Deewali becuase of These due Date. Pl extend so as to Join us in our Hindu Festivals

  3. RAJAT AGARWAL says:

    Respected Madam, Request you to extend due date atleast for one month, it will be helpful for filing peacefully. there has been issue in uploading the report on the portal. Please consider our request and do needful help Madam. Thank you.

  4. RAVI KUMAR says:

    I most humbly Prayed, that the due date of furnishing audit reports may kindly be extended from 30th Sept., 2022 to 31st Oct., 2022 to avoid any genuine hardship to the taxpayers. With Thanks & Regards RAVI

  5. Mohammed Ghouse Pasha Auditor says:

    Respected…
    To.
    The H,ble Finance Minister Govt of India..

    Dear Madam please extend the due date for filing of Tax Audit report from 30th September to 31st October…Please consider our request…

    Thanks…

  6. Vidya.R.Kendadmath says:

    Respected Madam,
    Request you to extend due date atleast for one month, it will be helpful for filing peacefully, by doing work with lot of tension is affecting on health also.
    Please consider our request and do needful help Madam.
    Thank you.

  7. ANUP DAS says:

    IT WILL BE A GREAT HONOUR AS NOONE IS READY TO UNDERSTAND THE POSITION AND SITUATION THAT WE FACE MAKE A SINGLE AUDIT. SO WE REQUEST THE AUTHORITY JUST A MONTH TO FURNISH EVERYTHING IN A COMFORTABLE WAY.

  8. Omprakash Malpani says:

    Tax audit due date extension at least by one month upto 31st October 2022 is very much need of hour for the reasons stated herein above

  9. Ravikumar Veggalam says:

    Respected Madam,
    Smt. Nirmala Sitharaman Ji,
    Pls consider the representation of ALL INDIA FEDERATION OF TAX PRACTITIONERS to -extend-due-date-for filing of -income-tax-Audit reports under Income Tax Act, 1961, from 30th September, 2022 to 31st October, 2022.
    Thanks & Regards
    Ravikumar Veggalam

    1. Vidya.R.Kendadmath says:

      Dear Madam,
      Request you to extend due date atleast for one month, it will be more helpful for practitioners, by doing work with more tension it may affect on health also Madam.

  10. KAVIPURAPU VENKATA SUBBA RAO says:

    Dear Finance Ministry team, the already tough tax audit due date has been preponed to September 30, from October 31 earlier, despite significant increase in complexities, such as clause 44 requirements, besides statutory audit being done at same time, with new Schedule III, new CARO requirements, multiple clients to be handed by auditors at same time, SME sector in particular facing very difficult challenges due to lack of adequate manpower, etc., health, weather & other challenges, Non corporate due date of July 31 affected time available earlier, most important to reduce stress, tensions of all involved, hence request to kindly extend due date of tax audit at least to original earlier date of October 31, thanks very much.

    Read more at: https://taxguru.in/income-tax/representation-extend-due-date-filing-income-tax-audit-reports.html
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  11. Amitava Choudhury says:

    Madam, please extended the date of filing tax audit report for 1 month only, since this is a festive month which will be over by mid of October, 22. Don’t be so hard, gives us a chance to file proper and error free audit reports

  12. sarfaraz nursuamr says:

    Respected Madam,
    Kindly extend the due date of TAR to 31st October,2022 as there are various new provisions incorporated in TAR and also it is very to difficult to file the TAR within 30th september

  13. Sudhir Kumar Tiwari says:

    Respected Ma’am. kindly extend income tax audit AY 2021-22 Due to heavy rain in Bundelkhand internet connections not working properly so high mental precure created pls give us some relax

  14. Surekha says:

    Please extend the date as bonus etc will be paid before filing of tax audit to avoid mismatches under Sec 43(b). Unnecessary time pressure due to some clauses. Please keep the date same for tax audit and filing of ITR.

  15. C V PROMOD says:

    Respected Madam and CBDT Members
    please extend filing date of TAX AUDIT REPORT and 10B report to 30th October 2022. I being a Senior Citizen practicing as Tax Consultant .With folded hands before you and members of CBDT . Please consider my plea.

  16. KAVITA GUPTA says:

    Res Mam

    Please extend the due date of Tax audit as compilation of details including Clause 44 is taking lots of time…also due to heavy rain at various places across country causing interruption in electricty supply and Internet services

  17. CA Mohan Rajan says:

    Dear Finance Ministry team, the already tough tax audit due date has been preponed to September 30, from October 31 earlier, despite significant increase in complexities, such as clause 44 requirements, besides statutory audit being done at same time, with new Schedule III, new CARO requirements, multiple clients to be handed by auditors at same time, SME sector in particular facing very difficult challenges due to lack of adequate manpower, etc., health, weather & other challenges, Non corporate due date of July 31 affected time available earlier, most important to reduce stress, tensions of all involved, hence request to kindly extend due date of tax audit at least to original earlier date of October 31, thanks very much.

    1. Priyanka Shah says:

      Please extend due date till 31st oct.
      This year we did tax audit in jan22.
      itr in march22.
      Caro new in may22.
      It’s hardly 4 months Sept 22 to do tax audit with applicable of new clause and prepare form 3cd.

  18. RATHINDRA BAKULY says:

    Respected Madam and Sir, Please consider the labourious job imposed on us to file Form 44 for each Tax Audit has become very much time consuming and a fear also being imported, lest putting any wrong figure may lead to disastrous and unnecessarily causing pain to the assessee and soaring demand-might lead to sleepless nights. Request you to kindly think of us and the honest assessees. Another point is the great festival period. Putting pressure = losing participation into festivals. We hope and trust that you will look into it and consider our agony.

    1. C V PROMOD says:

      Respected Madam and Members of CBDT
      With folded hands please extend time upto 31 Oct 2022 to file the Tax Audit Report and 10B report. I being a Senior Advocate and Tax Consultant
      Makes this plea before your goodselves and Members of CBDT

  19. Praveen kumar H R says:

    Preparation of audit and reporting takes time. New clause also time consuming. So we request to extend time to file tax audit report till 31/10/2022
    ………..

  20. VIJAY DHARNI says:

    why professional body is represting and requesting for extension .
    This move should come from Industries and Trade bodies.
    See tha nature of public they come only on the last dates either Spt / oct/ nov/ so on

  21. PAWAN KUMAR AGARWAL says:

    Most respectfully the gap between last tax audit report and this year tax audit report is usually 12 months . This year it is very less. Up to July 31st 2022 nothing has been started so far tax audit is concern due to non audit i tax retiurn filing. Preparation of audit and reporting takes time. New clause also time consuming. So we request to extend time to file tax audit report till 31/10/2022

  22. HR Subramanya Iyer says:

    Atleast, instead of submitting tar by 30th September, if it is amended as before submission of itr, it will be much useful.

    But I don’t think Govt will extend the due dates

  23. Anand Chand says:

    कृपया ध्यान दें:-माननीय प्रधान मंत्री/भारत के राष्ट्रपति/वित्त मंत्री विभिन्न प्राकृतिक कारणों/मानव अधिकार कारणों से हम आपके सम्मानों से अनुरोध करते हैं कि आयकर अधिनियम के विभिन्न प्रावधानों के तहत लेखा परीक्षा रिपोर्ट प्रस्तुत करने की नियत तारीख कृपया से बढ़ा दी जाए। 30 सितंबर, 2022 से 31 अक्टूबर, 2022 तक। धन्यवाद

  24. NARESH KUMAR MAHMIA says:

    PLEASE EXTEND DUE DATE OF SUBMISSION OF AUDIT REPORT.ACCOUNTS PROFESSIONAL IN HEAVY BURDEN. PLEASE EXTEND THE SAME AS SOON AS POSSIBLE FOR MAINTING THE QUALITY OF WORK.

  25. Bharat Sanklecha says:

    Preparation of audit and reporting takes time. New clause also time consuming. So we request to extend time to file tax audit report till 31/10/2022

  26. S.Prabhushankar says:

    Kind Attn:- Honourable Primer Minister/ President of India / Finance Minister
    Due to various Natural reasons/human right reasons we request your honours that the due date for furnishing of the audit reports under various provisions of the Income Tax Act may kindly be extended from 30th Sept., 2022 to 31st Oct., 2022.

    Thanks

  27. Devendra Kothari says:

    Hon FM the extension is need of hour to ensure proper and quality performance of Audit , secondly the issue of site which is very very slow and lesser time given for compliances by frequent changes in utility also effect the work schedule and delay in compliances. So please ensure proper and reasonable time for compliance.

  28. PROTIV KUMAR CHAKRABORTY says:

    I most humbly Prayed, that the due date of furnishing audit reports may kindly be extended from 30th Sept., 2022 to 31st Oct., 2022 to avoid any genuine hardship to the taxpayers. With Thanks & Regards Protiv Kumar Chakraborty,Advocate

  29. T Sreenivas says:

    Dear Sir/Madam
    I will be greatful if the time for filing Company returns from 30th Sept 22 to 31st Oct 22. I request the honourable minister for Finance Mrs. Nirmala Sitaraman to consider the request as most of the Companies are of the view for the same.
    I also request the madam to make it a rule which was earlier 31st July. Let it be at 31st July. Later extention by 15 days to one month can be made, so catagorically by 31st Aug almost everyone will complete the task.

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